In Chaidez v. United States, ___ U.S.___, ___n.16, ___ S.Ct.___, 2013 WL 610201 (Feb. 20, 2013), the court held Padilla did not apply to a post-conviction challenge to a federal conviction on grounds that counsel failed to advise the defendant concerning the immigration consequences of a plea in a case already final when Padilla was decided on March 31, 2010. Chaidez does not technically apply to review of state convictions in state court. It held merely that Padilla does not apply to cases already final on March 31, 2010, when it was decided. Favorable state authority, on independent state grounds, decided prior to Padilla holding defense counsels failure to advise, or affirmative misadvice, concerning adverse immigration consequences of a plea such as that in California, remains intact. This is particularly important in California, where state authority condemned failure to advise as ineffective assistance of counsel has existed since 1987. This prior authority does not depend on Padilla, and so remains useful even though Padilla itself does not apply to cases already final when it was decided.